Reporting suspected terrorism

Question: We just had special training on reporting suspected terrorism. We know about the special hotline but are confused about whether we should still file a traditional SAR?

Answer: The Financial Institutions Hotline, (866) 556-3974, is a number you can call to swiftly report suspicious transactions that may relate to terrorist activity. Using this number is voluntary, but we encourage you to do so. The faster such situations are reported, the more effective enforcement can be.

However, you should also file the traditional SAR. Following the SAR filing procedures provides your institution with the safe harbor protections. It also provides documentation of the report and the activity. For specific guidance (and in case anyone in your institution needs convincing) see FIL-87-2001 from the FDIC. This does a good job of explaining the responsibilities.

As we have encouraged you to do in previous issues of this newsletter, complete the SAR accurately and completely. Fill information where it is called for on the form. Don't simply use the "see attached" approach. Attached information doesn't go into the investigators' database and is thus useless. Do describe the nature of the suspicious transaction carefully and completely. Be thorough but succinct. Also include information on other institutions that appear to be involved, even if they are only part of the path of the transaction.

Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 2, 3/02